With less than three months until the launch of the Institute for Apprenticeships, and six months since the hunt for permanent board members began, the government finally wants your feedback on what the Institute should do.

But you won’t find any questions or options to choose from in the ‘Draft Strategic Guidance’, something we are accustomed to from previous apprenticeship ‘consultations’. It seems we’ve moved into a new and pragmatic phase of policy making, where feedback should simply be emailed before the end of January to an old BIS account: [email protected]

This informal approach to ‘consultation’ is unsurprising given there is so little time before the Institute launches.

And we should take all DfE requests for feedback seriously.

After all, their new permanent secretary, Jonathan Slater, said in an interview with Civil Service World last month that he and the Secretary of State had just launched a “change programme” at the DfE and “listening is at the heart of it.”

They would be “listening to customers” in 2017 because “policymaking is so much better when we listen first to our customers and to the evidence, before deciding what to do.”

So what do the eight pages of roles and responsibilities tell us and do we think the Institute will succeed as the “guarantor of the integrity of the apprenticeships system”?

There are no surprises in terms of what the Institute will do, which is summed up as having a “mandate to assure quality and provide objective advice on future funding for apprenticeship training.”

In the main, the DfE will offload to the Institute the responsibility for the approval or rejection of new apprenticeships standards and assessment plans, along with the ongoing quality assurance of those approved.

With over 500 standards already approved or in development and many hundreds more likely to be applied for, that should keep the Institute busy.

But its “policy parameters” won’t end with taking over where the DfE team left off. Staff at the Institute will also be expected to duplicate the work of Ofqual, providing external quality assurance for some apprenticeship assessments. They will also duplicate the work of the Skills Funding Agency, advising on the key quality criteria for both the provider and assessment organisation registers as well as giving advice and assistance on apprenticeship funding. Plus, and seeing is believing, the Institute will have new statutory powers to “discourage” abuse of the system (something the SFA may rightly be envious of).

This “independent” Institute “led by employers” will do all this duplication whilst at the same time being pushed around by the government, because it will need to align apprenticeships to the so far unpublished Industrial Strategy, support “wider Government priorities like social mobility”, transition to the new and evolving post-16 framework of 15 technical education routes, support the 3m starts target, work with Ofsted, QAA and devolved nations… the list goes on.

On the question of whether the Institute will succeed, or suffer the same fate as the UKCES, there appear to be two major barriers that need careful navigation.

Firstly, beyond the monumental task of managing the approval and ongoing maintenance of hundreds of standards, duplication with existing agencies like Ofqual and the SFA will create confusion, animosity and ultimately buck passing. This is not something the government and ambitious ministers will tolerate for long.

Secondly, the government says it is putting employers in the driving seat, taxing them via a levy but in return giving them control of its use. But each year, these employers on the institute board, chosen by the government, will receive their directions in an annual ‘statutory notice’. It is only a matter of time before the Industrial Strategy, or social mobility priorities, or the ‘transition to a fully integrated system of technical education’ sends the car into a spin. Employers and a backseat driving government fighting each other for control of the wheel.

So scale back on the duplication and stop pretending that employers know best how to drive. The Institute should focus on the unglamorous but important task of working with engaged employers to develop and maintain a full range of high quality standards. Funding and financial assurance should rest with the SFA, quality assurance of delivery with Ofsted (including degree apprenticeships) and regulation of assessment and the relevant organisations with Ofqual.

That then leaves the government to necessarily intervene in market failures, such as ensuring high levels of social mobility and economic prosperity in a post-Brexit Britain.

All the wiring is there for a high priority, quality and quantity apprenticeship system. It just needs careful untangling.